Here is our latest review and assessment of major AI-related disputes in the media and entertainment sectors.
Our AI Litigation Tracker is prepared by McKool Smith principal Avery Williams in collaboration with AI and media expert Peter Csathy of Creative Media, a leading consulting firm specializing in AI, media, entertainment, and technology. The Tracker is also featured in Peter's weekly newsletter the brAIn.
1. Kadrey et al. v. Meta
Background: Author Richard Kadrey, comedian Silverman, and others sued Mark Zuckerberg’s Meta on July 7, 2023 in the U.S. District Court (Northern District of California) for mass infringement - i.e., unlicensed “training” of their generative AI model on millions of copyrighted works, including their own. Meta’s defense is “fair use.” The judge assigned is Judge Vince Chhabria.
At first, in November 2023, the Court dismissed the bulk of plaintiffs’ claims against Meta. But the Court gave plaintiffs a chance to amend their complaint to add a more direct link to actual harm - and they filed their amended complaint in December 2023.
Current Status: You can never have too many amici. This week included a flurry of amici briefing in support for Plaintiffs at summary judgment. Plaintiffs have asked the Court to find that Meta’s “fair use” defense fails, arguing (a) that Meta’s undisputed piracy of copyrighted works nullifies its fair use defense as a matter of law, and (b) that regardless of Microsoft’s admitted piracy, it can’t succeed under the four fair use factors.
Plaintiffs’ piracy argument hinges on whether the illegal acquisition of copyrighted data cuts off the possibility of subsequent fair use. Plaintiffs argued that it did, both because Meta downloaded the books and, independently, because it engaged in seeding which redistributed the pirated books to others. With respect to the fair use factors, Plaintiffs argued that Meta’s Llama LLM was a tool for mimicry and not a transformative use, that Meta’s use of the entirety of Plaintiffs books for training favored factors two and three, and that Meta was attempting to snuff out the nascent market for training data by which the Plaintiff-authors could be compensated for Meta’s use of their books.
This week’s amici included the “Copyright Law Professors,” whose brief directly opposed that of last week’s IP Law Professors. The Copyright Law Professors argued that Meta’s fair use defense amounted to a request for special legal privileges exempting a for-profit corporation from complying with copyright law so it could build its LLM. The Professors argued that the use of books to train LLMs was not so different from the use of books to educate humans, which has not been held to be a fair use justification for wholesale copying. They also argued that Meta’s LLMs do compete directly with Plaintiffs, pointing to the decline in the freelance writing market that has followed the introduction of LLMs.
The “competition” argument is an interesting one. Copyright law typically considers competition with a work –- a replacement for the copyrighted work itself. The LLM is something deeper and far more concerning — replacement of the worker. We will have to see the extent to which that argument will fit within in the fair use analysis.
The amici also included the International Association of Scientific, Technical, and Medical Publishers (STM). The STM’s brief harshly condemned Meta’s conduct, devoting half its length to an accounting of the illegality and notoriety of the sources from which Meta torrented data. Based on this, STM argued that “Meta’s brazen acts of infringement, unprecedented in the annals of copyright law . . . should weigh heavily against [fair use].”
Another amicus from the Copyright Alliance opposed Meta’s fair use defense, distinguishing the authority that Meta used in support of its argument based on the Supreme Court’s 2023 decision in Andy Warhol Found. v. Goldsmith. In Warhol, the Court found that the “ultimate purpose” of the purported fair use must be considered. The Alliance argued that in isolating the “training” aspect of its use, Meta ignored that the ultimate purpose of training LLMs was to generate output that serves the same purpose as the ingested works. In distinguishing Google Books (which Meta called the “most factually analogous case”), the Alliance argued “Meta’s Llama cannibalizes Plaintiffs’ copyrighted works for the purpose of allowing its users to manufacture the same type of works” and therefore threatened the market for Plaintiffs’ works.”
Still another amicus brief by the Association of American Publishers (AAP) argued that LLM training is not a transformative use because it consists of encoding the expressive content of works used for training. The AAP also argued that Meta’s fair use argument attempts to undermine the rapidly expanding market for licensing works to be used for training LLMs and is confounded by Meta’s use of pirated works.
It's fascinating to see every party finally putting their cards on the table. The first ruling on fair use in one of these cases is going to send shockwaves through the industry one way or another. Stay tuned for all the updates!
2. MDL Consolidation order!
Special Report: Federal Judge Stein in the S.D.N.Y appears to be the multi-district litigation (MDL) judge for twelve high-profile generative AI cases. On April 3rd, the MDL panel consolidated the following cases for pretrial proceedings:
1. TREMBLAY, ET AL. v. OPENAI, INC., ET AL., C.A. No. 3:23−03223
2. SILVERMAN, ET AL. v. OPENAI, INC., ET AL., C.A. No. 3:23−03416
3. CHABON, ET AL. v. OPENAI, INC., ET AL., C.A. No. 3:23−04625
4. MILLETTE v. OPENAI, INC., ET AL., C.A. No. 5:24−04710Southern District of New York
5. AUTHORS GUILD, ET AL. v. OPENAI, INC., ET AL., C.A. No. 1:23−08292
6. ALTER, ET AL. v. OPENAI, INC., ET AL., C.A. No. 1:23−10211
7. THE NEW YORK TIMES COMPANY v. MICROSOFT CORPORATION, ET AL.,C.A. No. 1:23−11195
8. BASBANES, ET AL. v. MICROSOFT CORPORATION, ET AL., C.A. No. 1:24−00084
9. RAW STORY MEDIA, INC., ET AL. v. OPENAI, INC., ET AL., C.A No. 1:24−01514*
10. THE INTERCEPT MEDIA, INC. v. OPENAI, INC., ET AL., C.A. No. 1:24−01515
11. DAILY NEWS LP, ET AL. v. MICROSOFT CORPORATION, ET AL.,C.A. No. 1:24−03285
12. THE CENTER FOR INVESTIGATIVE REPORTING, INC. v. OPENAI, INC., ET AL.,C.A. No. 1:24−04872
*As discussed below in the Raw Story Media update, Raw Story Media appears to be over pending appeal as the court in that case rejected the Plaintiffs’ attempts to file an amended complaint.
In granting the MDL consolidation, the panel rejected Plaintiffs’ concerns about a lack of uniformity among the claims and the claimants, saying that the differences between the training claims, the output claims, and the DMCA claims were not a “significant obstacle to centralization given the substantial overlap in factual questions and discovery relating to defendants’ training of their LLMs.”
Although the Plaintiffs generally opposed MDL consolidation (as plaintiffs frequently do), they preferred S.D.N.Y. over the Northern District of California, which is also not surprising, as the Northern District of California has a reputation as a business-friendly venue for intellectual property disputes. So while Plaintiffs probably aren’t happy about the delays and loss of control that come with MDL consolidation, at least they’re not in an unfriendly venue.
Let’s keep our fingers crossed for a bellwether trial we can really sink our teeth into!
3. In re OpenAI ChatGPT Litigation
Background: Comedian Sarah Silverman and other artists filed this class action lawsuit in the Northern District of California on June 28th, 2023, asserting copyright infringement claims, in addition to unfair competition, negligence, and unjust enrichment. Plaintiffs alleged that OpenAI used their copyrighted written works to train its AI chatbot. In February, the Court dismissed most of the claims against OpenAI, rejecting Plaintiffs’ argument that the content generated by ChatGPT (i.e., the “output”) infringes their copyrighted works because there is no “substantial similarity” on the “output” side of the copyright question (and, therefore, no meaningful harm). But the Court gave Plaintiffs an opportunity to amend their complaint to plead a more direct link of harm (which they later did). In July, the Court dismissed the unfair competition claim. The claim for direct infringement is the only main one that remains. The case is assigned to Judge Araceli Martinez-Olguin.
Current Status: Vacated following transfer to SDNY. These cases were among those transferred to the Southern District of New York in the Multidistrict Litigation transfer order discussed in 2 above. On April 8th, the Court vacated its upcoming April 17th hearing on Plaintiffs’ motion for leave to amend their complaint in light of the transfer order.
4. Thomson Reuters v. Ross Intelligence: The “Fair Use” Shot Heard Around The Litigation World
Background: On February 11th, in a case that comes tantalizingly close to deciding the issue of “fair use” in generative AI model training (with many taking the position that now that issue is firmly decided, as laid out below), Circuit Judge Bibas of the District of Delaware ruled that the “fair use” doctrine does not protect the use of West Headnotes in determining what to display as a result of a user query. Thomson Reuters v. Ross Intelligence involves an AI search tool made by the now-defunct Ross Intelligence (“Ross”). Ross’ tool accepted user queries on legal questions and responded with relevant case law. To determine what cases to provide in response to user queries, Ross compared the user queries to “Bulk Memos” from LegalEase, which were written using Westlaw Headnotes. Boiling it down, when a user’s query contained language similar to a West Headnote, Ross’ tool would respond by providing the cases that the West Headnote related to.
While Ross’s tool was not a modern generative AI model (it didn’t use a transformer model or perform next-token prediction to generate unique output for queries), an important similarity exists between Ross’ use of West Headnotes and the way generative AI models train on other copyrighted materials. Ross’ tool did not actually reproduce the West Headnotes in response to a user’s query. Ross used the Headnotes just for “training,” that is, to determine what to produce in response to a user's query. It is easy to draw an analogy between Ross’ use of West Headnotes to determine what cases are responsive to a user’s query, and OpenAI’s use of The New York Times articles to determine how to respond to a question about politics (see the separate The New York Times case against OpenAI summary below). The technology is different, but the themes are similar.
In that context, the Court’s grant of summary judgment against Ross’ fair-use defense — as a matter of law — provides insight into how another court might rule in a generative AI training case. “Fair use” is based on four factors: (1) the purpose and character of the use, (2) the nature of the copyrighted work, (3) the amount of the work used, and (4) the potential impact on the market. The Thompson Reuters Court found that factors two and three favored Ross because of the low degree of creativity involved in carving out headnotes from cases, as well as the fact that Ross did not output the headnotes themselves but rather judicial opinions. However, factor one favored Thomson Reuters because of the commercial nature of Ross’ product and the fact that it was not transformative. The Court noted that Ross’ product was not generative AI, suggesting that a generative AI product could be more transformative than the simpler lexical searching tool that Ross made. Finally, the fourth factor and “undoubtedly the single most important element of fair use” favored Thomson Reuters because of the potential impact on Thomson Reuters’ ability to sell its own data for use in training AI if Ross’ use was permissible. On balance, the Court flatly rejected Ross’ “fair use” defense as a matter of law. That question will not go to a jury.
AI developers will undoubtedly focus on the issue of transformative-use in generative AI fair-use battles to come, but the “commercial use” and “market impact” factors will continue to favor content owners over generative AI companies. We have already seen several massive licensing deals where companies like Reuters and Reddit are profiting from the sale of their own data. If courts continue to favor the “market impact” factor as we see in Thompson Reuters, then OpenAI, Suno, and the like will have an uphill battle to prove their “fair use” defense.
Current Status: MAJOR UPDATE: The Court certifies Ross’ fair-use and copyrightability arguments for interlocutory appeal. On April 4, the Court granted Ross Intelligence’ motion for interlocutory appeal off the Court’s summary judgment ruling against Ross’ “fair use” and copyrightability arguments. The Court stated that “Though I remain confident in my February 2025 summary judgment opinion, I recognize that there are substantial ground for difference of opinion on controlling legal issues in this case.” The two questions certified are “(1) whether the West headnotes and West Key Number System are original; and (2) whether Ross’s use of the headnotes was fair use.”
We’re not particularly surprised at this development. The country is watching this case rather closely because of its proximity to the GenAI training cases, and the hundreds of billions of dollars at stake there. Trying the case without considering the certified questions, and then having those issues reversed on appeal could waste everyone’s resources.
5. Raw Story Media & Alternet v. OpenAI
Background: News publishers Raw Story Media and Alternet filed suit against OpenAI and Microsoft on February 28th, 2024 in the Southern District of New York, claiming their articles were used to train the LLM that powers OpenAI’s ChatGPT. Rather than claiming copyright infringement, Plaintiffs alleged one cause of action for violating the DMCA (which is a separate provision of the Copyright Act related to Internet content). Plaintiffs claimed that OpenAI removed the CMI from their articles, which they argue is a violation of the DMCA.
Current Status: Raw Story Media’s motion for leave to amend denied! Two months ago, we reported that Raw Story Media was down to their last chance to maintain their lawsuit by asserting that the removal of copyright management information (CMI) by OpenAI constitutes copyright infringement, which is a recognized harm under Article III and that OpenAI unlawfully profited from this removal, which is analogous to unjust enrichment.
This week, the Court denied Raw Story Media’s motion, finding that Plaintiffs continue to assert the same injury that failed in their first complaint. According to the Court, Plaintiffs’ addition of technical detail was not enough to render Plaintiffs’ asserted harm more concrete, despite the ruling in The Intercept Media that Plaintiffs pointed to last week. According to the Court, “[i]f Plaintiffs believe that I got it wrong and my esteemed colleague Judge Rakoff got it right . . . [s]eek review before Second Circuit.” The Court found Plaintiffs’ unjust enrichment analogue to be even further from the mark, and was similarly unpersuaded that Plaintiffs had standing for injunctive relief (which it said “was going to be a tall order”).
It appears that Raw Story Media is out of the running for now, though they may very well be filing briefs soon with the Second Circuit.
6. The New York Times v. Microsoft & OpenAI
Background: This is perhaps the single most closely watched litigation involving copyright owners and generative AI tech companies.
On December 27, 2023, The New York Times sued Microsoft and OpenAI in the U.S. District Court for the Southern District of New York for copyright infringement and other related claims. The Times alleges that the companies used “millions” of its copyrighted articles to train their AI models without its consent. The Times claims this has resulted in economic harm by pulling users away from their paywalled content and impacting advertising revenue. The complaint alleges several causes of action, including copyright infringement, unfair competition, and trademark dilution. In its pleadings, The Times asserts that Microsoft and OpenAI are building a “market substitute” for its news and further that their AI generates “hallucinations” based on The Times’ articles also substantially damage its reputation and brand. The Times seeks “billions of dollars of statutory and actual damages.” Microsoft and OpenAI assert the defense of “fair use” - i.e., no license, payment or consent is needed.
On September 13, 2024, the Court granted a motion to consolidate the case with another brought by the Daily News and other publications. The judge assigned to the consolidated cases i Judge Sidney Stein.
Current Status: No major substantive developments this past week. This week saw little development following the April 3rd Multidistrict Litigation transfer order that centralized twelve matters (discussed above), all involving OpenAI and Microsoft’s LLM training, in the Southern District of New York. The Court extended the Defendants’ time to answer in the Newspaper cases and it appears likely that further extensions to scheduling will be made as the Court accounts for the change in its docket.
7. Concord Music Group, et al. v. Anthropic
Background: UMG, Concord Music and several other major music companies sued Amazon-backed OpenAI competitor Anthropic on October 18th, 2023 in the U.S. District Court (Middle District of Tennessee). The music companies assert that Anthropic is infringing their music lyric copyrights on a massive scale by scraping the entire web to train its AI, essentially sucking up their copyrighted lyrics into its vortex – all without any licensing, consent or payment. In its response, Anthropic claimed fair use. The case was transferred to the Northern District of California on June 26th, 2024 and closed in Tennessee. The judge assigned is Judge Eumi K. Lee. The parties have not yet had a case management conference.
Current Status: No major substantive developments this past week. Last week the Court ruled against Plaintiffs in their request for a preliminary injunction as well as on Defendant’s motion to dismiss. This week, however, brought fewer developments, with the docket consisting of little more than administrative items and the parties’ joint stipulation to extend time to submit a proposed sampling protocol.
8. Brave Software, Inc. v. News Corp., et al.
Current Status: No major substantive developments this past week. No new developments have taken place yet in this newly filed case but check back here to find out when they do.
As reported last week: Brave Software filed an action for declaratory judgment of no copyright infringement, copyright misuse, and no breach of contract against News Corp, Dow Jones, and NYP Holdings. Brave distributes the open-source Brave browser, which blocks ads and trackers while displaying its own limited set of ads as a source of revenue for the company. Brave Software also developed Brave Search, which exited beta in mid-2022 and which serves as the default search engine in the Brave browser. Brave Search is also significant because it is the search engine which certain AI chatbots such as Perplexity, Mistral, and others make use of. Brave filed its declaratory judgment action following the receipt of cease-and-desist letters from the named Defendants.
The allegations are that Brave, by indexing Defendants’ websites in order to enervate its Brave Search engine, infringed on Defendants’ copyrights and breached their terms of service. In its complaint, Brave characterized these allegations as baseless bullying intended to prevent new entrants to the sectors already dominated by Big Tech. Brave maintains that its indexing is well-established fair use and non-infringing. Although it does not directly implicate LLMs, this case’s relation to AI cannot be denied. Not only is Brave Search used by several AI chatbots, the allegations at issue also track the logic of copyright infringement theories alleged by artists and authors against AI companies. As always, we will keep you updated here each week as the case develops.
9. UMG Recordings v. Suno
Background: The RIAA on behalf of the major record labels filed their lawsuit in the federal district Court in Massachusetts on June 24th, 2024, for mass copyright infringement and related claims based on alleged training on their copyrighted works. Suno is a generative AI service that allows users to create digital music files based on text prompts. This is the first case brought against an AI service related to sound recordings. In its answer on August 1st, 2024, Suno argued that its actions were protected by fair use. The judge assigned is Chief Judge F. Dennis Saylor, IV.
Current Status: No major substantive developments this past week. As we reported several weeks ago, Plaintiff and Defendant have both noted inability to resolve their disagreements over discovery matters. Though there have not been many major developments in the past week, Defendant did file a notice of supplemental authority referencing the successful motion to compel in UMG Recordings v. Uncharted Labs to support their analogous request for documents related to ownership.
10. UMG Recordings v. Uncharted Labs (d/b/a Udio)
Background: This case was brought on June 24, 2024, in the Southern District of New York, by a group of major record companies against the company behind Udio, a generative AI service launched in April 2024 by a team of former researchers from Google Deepmind. Much like Suno (above), Udio allows users to create digital music files based on text prompts or audio files. And as with the complaint against Suno, Plaintiffs rely on tests comprising targeted prompts including the characteristics of popular sound recordings — such as the decade of release, the topic, genre, and descriptions of the artist. They allege that using these prompts caused Udio's product to generate music files that strongly resembled copyrighted recordings. The claims are for direct infringement and related causes of action. The judge assigned is Judge Alvin K. Hellerstein.
Current Status: No major substantive developments this past week. Two weeks ago we reported that the Court had denied Plaintiff’s request for extension of time to amend their complaint, stating that they could seek leave to file an amended complaint at any convenient time. This week brought few new developments, though the Court did grant Defendants’ motion to compel production of deposit copies of the asserted works and works made for hire agreements over Plaintiffs’ objections.
11. Dow Jones & Co, et al v. Perplexity AI
Background: On October 21st, 2024 The Wall Street Journal and The New York Post sued generative search company Perplexity AI in the U.S. District Court for the Southern District of New York for copyright infringement and other related claims. A new twist in this litigation is the focus on Retrieval Augmented Generation (“RAG”) AI. RAG GenAI not only uses an LLM trained on copyrighted material to respond to individual prompts, but also goes out to the web to update itself based on the relevant query. Perplexity even said the quiet part out loud, encouraging its users to “skip the links” to the actual sources of the copyrighted content. Based on Perplexity’s RAG model, the media Plaintiffs allege that Perplexity is infringing on their copyrights at the input and output stage, sometimes reproducing copyrighted content verbatim. Plaintiffs cited their parent company News Corp’s recent licensing agreement with OpenAI in explaining that GenAI technology can be developed by legitimate means.
Current Status: No major substantive developments this past week. Two weeks ago we reported that Plaintiffs submitted their memorandum of law opposing Defendant’s motion to dismiss or transfer the case. Last week, Perplexity submitted its reply arguing that the Court lacked personal jurisdiction due to insufficient contacts with New York. No new developments occurred this week but check back soon to find out how Defendant’s motion resolves.
12. Sarah Andersen v. Stability AI
Background: Visual artists filed this putative class action on January 13th, 2023, alleging direct and induced copyright infringement, DMCA violations, false endorsement and trade dress claims based on the creation and functionality of Stability AI’s Stable Diffusion and DreamStudio, Midjourney Inc.’s generative AI tool, and DeviantArt’s DreamUp. On August 12th, 2024, the Court dismissed many of the claims in Plaintiffs’ first amended complaint, leaving the claims for direct copyright infringement, trademark, trade dress, and inducement. The assigned judge is Judge William H. Orrick.
Current Status: No major substantive developments this past week. Last week we reported that the Court had ruled on Plaintiffs’ request for 60 depositions, granting them only 30. Although this week brought no major developments, the parties have continued to litigate discovery, with Defendants arguing that Plaintiffs should be further limited by having depositions of former employees included within the 30-deposition limit and reducing the number of ESI custodians to five per party. Plaintiffs, in turn, argued that the magistrate judge erred in limiting the number of ESI search terms they could use as well as in limiting the discovery of documents hyperlinked in other produced documents.
13. Getty Images v. Midjourney and Stability AI
Background: Getty Images filed this lawsuit against image generator Stability AI on February 2nd, 2023, accusing the company of infringing more than 12 million photographs, their associated captions and metadata, in building and offering Stable Diffusion and DreamStudio. Getty’s claims are similar to those in The New York Times v. Microsoft & OpenAI case above, but here they are in the context of visual images instead of written articles - i.e., unlicensed scraping by their AI with an intent to compete directly with, and profit from, Getty Images (i.e., market substitution). This case also includes trademark infringement allegations arising from the accused technology’s ability to replicate Getty Images’ watermarks in the AI outputs. Getty filed its Second Amended Complaint on July 8th, 2024, and the parties are currently engaged in jurisdictional discovery related to Defendants’ motion to transfer the case to the Northern District of California. The judge assigned is Judge Jennifer L. Hall.
Current Status: Still no update for Getty. Still no update for Getty. The parties remain deadlocked on discovery as the court considers Stability AI’s jurisdictional arguments. Briefing has been complete for several weeks. We will update you the moment we hear anything.
14. The Intercept Media v. OpenAI
Background: The Intercept Media, a news publisher represented by the same firm that represents the plaintiffs in the Raw Story Media litigation below, filed suit against OpenAI and Microsoft on February 28th, 2024 in the Southern District of New York, the same day Raw Story Media commenced their suit. Like the Raw Story allegations, The Intercept alleged that their articles were used to train ChatGPT and brought claims for the removal of the copyright management information (“CMI”) from the articles.
Current Status: No major substantive developments this past week. Nothing new since OpenAI filed its answer to The Intercept’s First Amended Complaint on December 6th, 2024. OpenAI presented 10 affirmative defenses, including fair use, several equitable doctrines, statute of limitations, lack of mitigation, and failure to state a claim.
15. The Center for Investigative Reporting v. OpenAI
Background: The Center for Investigative Reporting, which produces Mother Jones and Reveal, sued Microsoft and OpenAI for essentially the same claims made in The New York Times case above.
Current Status: Motion to consolidate recently granted! Microsoft and OpenAI asked the Court to consolidate this case with NY Times v. Microsoft & OpenAI, and — and, as indicated above, the Magistrate granted the motion to consolidate on October 30th, 2024 (refer to the activity discussed above).
16. The Authors Guild, et al. v. OpenAI
Case Background. The Authors Guild and seventeen individual authors (including John Grisham, George R.R. Martin and Nicholas A. Basbanes) filed a putative class-action suit against OpenAI on September 19th, 2023. Plaintiffs claimed that OpenAI trained its ChatGPT LLM by copying their copyrighted works. The complaint brings claims under 17 U.S.C. §501 for direct, vicarious, and contributory copyright infringement. The case is assigned to Judge Ona T. Wang.
Current Status: No major substantive developments this week. We are still waiting for the Court’s decision on discovery consolidation. The case seems to be on ice until then.
17. INTERNATIONAL CASE TRACKED: Canadian News Media Companies v. OpenAI
In a case similar to The New York Times v. OpenAI, Canada’s major news organizations sued OpenAI for copyright infringement on November 28th. Filed in Ontario’s Superior Court of Justice, the news organizations are seeking billions of dollars in compensation for the “ongoing, deliberate, and unauthorized misappropriation of the Plaintiffs’ valuable news media works.” This is the first case of its kind in Canada, and presents a new front against OpenAI, after one was opened in Germany in Gema v. OpenAI as reported last week.
See https://litigate.com/assets/uploads/Canadian-News-Media-Companies-v-OpenAI.pdf
18. INTERNATIONAL CASE TRACKED: GEMA v. OpenAI
GEMA, a German association representing more than 95,000 composers, lyricists and publishers, filed suit in German court accusing OpenAI of reproducing their members’ song lyrics without a license. Gema claims this is a test case to clarify the law in Germany, and that it aims to establish a license model that would compensate music creators whose works are used to train AI models. The details of German copyright law are a bit beyond the scope of this blog, but we did think it noteworthy that the litigation trend is catching on worldwide. While we don’t plan to track this case closely, we will watch for any momentous developments.